Welcome to the privacy policy of Essence Capital Group, Inc. ECG Futures is a registered ‘dba’ of Essence Capital Group, Inc.

Protecting your confidential information

We, at Essence Capital Group, Inc., value our relationship with each of our customers, and we appreciate the trust that you have placed with us. We recognize that you have concerns about the confidential personal information we obtain about you throughout our relationship. Because protecting your confidential information is important to us, we have adopted a privacy policy, which governs how the confidential information we obtain about you is used and maintained. We pledged to protect that information and ensure that it remains private. The information in this notice summarizes the categories of personal information that we collect about you, how that information is handled, and how we protect that information.

Collection and Use of Personal Information

The privacy policy set forth in this notice applies to Essence Capital Group and affiliated companies of Essence Capital Group. We collect nonpublic personal information about you from the following sources, solely for the purposes specified:

• Information we receive from you on account applications or other forms, such as name, address, federal tax identification number, income, assets and similar information. It also includes names and addresses when that information is included in a list derived in whole or in part from nonpublic personal information, such as a list of the firm’s customers. We use this information to administer the accounts we maintain on your behalf, process transactions requested by you, respond to your inquiries, evaluate your investment needs, and identify other products and services that may interest you.

• Information about your transactions with us or our affiliates, such as your account balance, transaction history and payment activity. This information is used to process transactions you request and ensure the accuracy of the records and reports we maintain that relate to your account. We may also collect various other types of data, such as transaction site navigation and optional survey information, in connection with your use of online services we make available to you through other entities. We use this information in order to improve the quality of the services we offer to you.

• Information we receive from consumer reporting agencies, such as credit relationships and credit history. We use this information to help determine your eligibility for Essence Capital Group products and services, collect or report debts owed to us, and protect our rights and property.

Cookies

We use cookies and web beacons (also known as action tags or single-pixel gifs), and other technologies (collectively, “cookies”) to provide us with data we can use to improve your experience and to know you better. Cookies are small text files sent from Web servers that may be stored on your computer. Cookies enable us to capture how you arrived at our site, when you return, which pages on our site you visit, and to recognize that you are already logged on when we receive a page request from your browser. We may link the information we store in cookies to personally identifiable information you submit while on our site. We will never share this information with any 3rd party. Cookies are readable only by us and do not contain any personal information nor do they contain account or password information. We cannot and will not gather information about other sites you may have visited. We may share website usage information about visitors with reputable advertising companies for the purpose of targeting our Internet banner advertisements. The information shared is not personally identifiable. We may also use 3rd party software to track and analyze usage and volume statistical information including page requests, form requests and click paths – this tracking may set cookies on behalf of Essence Capital Group. All web browsers have settings that allow you to block cookies. By visiting our website with your browser set to allow cookies, you consent to our use of cookies as described above. If you choose to block cookies you may use our services but some functions may not work as designed.

Sharing of Information with Affiliated and Non-affiliated Parties

Essence Capital Group does not sell personal information regarding our current or former customers. Essence Capital Group may share information with affiliates if the information is required to provide the product or service you have requested or to provide you the opportunity to participate in the products or services our affiliates offer. To help us improve our services to you, we may engage another business to help us carry out certain internal functions, such as account processing, fulfillment, client service, client satisfaction surveys or other data collection activities relevant to our business. We may also provide a non-affiliated third party with client information from our database, including your name, address, phone number, and/or e-mail address, to help us analyze and identify client needs, notify clients of product and service offerings or conduct general marketing and market research for us. Essence Capital Group also forges partnerships and alliances with non-affiliated third parties which offer high-quality products and services that might be of value to our clients. In order to ensure that these products and services meet your needs and are delivered in a manner that is useful and relevant, Essence Capital Group may share some personal information with these non-affiliated third parties. We require that all non-affiliated third parties to which we provide your nonpublic personal information agree to keep your information confidential and use such information solely for the limited purpose for which we have engaged them, or as otherwise required by law. We also seek to ensure that these non-affiliated third parties maintain appropriate data security procedures to guard against unauthorized use of, or access to, your personal information. When required by law, Essence Capital Group reserves the right to disclose your personal information to third parties or regulatory, law enforcement or other government authorities. We may also disclose your information to credit reporting or collection agencies, or when necessary to protect our rights or property.

Opt-Out Notice

With respect to our sharing of your personal information with non-affiliated third parties, you may inform us that you would like to Opt-Out of such disclosure by contacting Essence Capital Group’s Compliance Office at +1 (847) 545 0959, or by sending an email to support@ecgfutures.com

‍Protecting the Confidentiality of Your Personal Information

Only authorized Essence Capital Group employees, agents or service providers will have access to your personal information. Each of them is held to the highest standards of privacy and security. All Essence Capital Group’s employees are instructed to use strict standards of care regarding the confidentiality of your nonpublic personal information as outlined in firm policies. Employees not adhering to our firm policies are subjected to disciplinary action. We implement appropriate technical and organizational measures to ensure a level of security to potential risks, which include:

• Password protection and encryption of your personal information where appropriate;

• ensuring ongoing confidentiality, integrity, availability and resilience of processing systems and services;

• ensuring we can restore access to personal information in a timely manner if a physical or technical incident occurs; and

• regular testing, assessment and evaluation of the effectiveness of our technical and organizational measures to ensure your personal information is secure. We maintain physical, electronic and procedural safeguards to protect the confidentiality and security of personal information transmitted to us.

Changes in Notice

If this Privacy Policy changes you will be notified through the ECG Futures web site or in other appropriate ways. If you have any questions or comments about our privacy policy, please contact Essence Capital Group’s Compliance Office at +1 (847) 545 0959, or by sending an email to support@ecgfutures.com